Letters

UAS in the NAS

I had occasion to read Emily Feliz’s Editor’s Note in the September issue. I have no quarrel with what she says; it is just that she did not go far enough to outline the bigger picture.

The subject of the Editor’s Note is the huge problem of integrating Unmanned Aircraft Systems (UAS) into the National Airspace System (NAS). The major problem, as I see it, is the failure of Congress to look at all of the many pieces of the issue before passing the mandate to get it done, and putting a complete-by date on it while essentially acting in ignorance, and leaving out the Constitution as the measuring stick. As Feliz points out, “what exact steps are needed to ensure the safety of operators of manned and unmanned aircraft in the same airspace are unclear.”

Three possible missions for UASs in the NAS were cited in the article resource management, border patrol, and search and rescue. As an old MEDEVAC pilot, I can see how they could aid in search and rescue, but not replace EMS helicopters with the onboard medical professionals, medical expertise and equipment. Resource management can be accomplished by already existing satellites, and so could border patrol, unless you are talking armed UASs which raises another big issue.

During the last 100 years, freedom, liberty and independence have been steadily eroded by the accelerated growth of the central government. Along with the explosion of laws comes the explosion in bureaucracy. It has clearly gotten to the point that the federal government is just about uncontrollable with the inevitable result that we are seeing more and more chaos. Is there any wonder Feliz states, “In addition, the industry faces the big task of changing public perceptions of the ‘drones’ that could darken the airspace, invading our privacy.”

Finally, from the point of view of a pilot using the NAS, I do not relish sharing it with UASs, and/or having to buy additional proximity warning devices to install in my airplane. As I showed above, there is no compelling need to allow UASs to fly in the NAS.

It is time for all citizens to make the effort to find out and understand current events in the illuminating light of history. It is a fact that it repeats itself.

Mike Stoner is a retired Army colonel, aircraft maintenance officer, test pilot and commercial pilot flying Part 135 operations in support of the oil and gas industry.

Tin Whiskers

I read with interest Walter Shawlee 2’s informative article on the undesirable consequences of the EU’s “policy- driven, not science-driven” Restriction of Hazardous Substances (RoHS) Directive, and in particular, tin whiskers.

RoHS, and WEEE, from which it was split, were created without any finding of public health or environmental damage attributable to the use of the restricted substances in electrical and electronic equipment. There was no finding of public health damage because there is none, including unregulated recycling in third-world countries.

Regrettably, unregulated recycling in third-world countries is damaging the local environment, but since it is already illegal, the effect of the RoHS directive on lawbreakers is nil.

One can’t understand the above two directives without understanding the “Precautionary Principle,” which the environmental activists who promoted them had previously introduced as nothing more than an expression of common sense. Consider these two formulations:

1. When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically.

2. In order to protect the environment, the precautionary approach shall be widely applied by States according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.

Where there are “threats” of harm, both formulations give the rationale for acting without proof. While at first glance they may look OK, neither is at all common sense. Both are fatally flawed. In fact, without an established cause-effect relationship, there can be no way to determine whether the proposed “precautionary measures” are either necessary or sufficient.

The second formulation introduces the notion of cost-effectiveness. But if the original activity is only suspected of causing harm, by what means is the safety and effectiveness of the remedy to be determined?

To see how complicated (and ultimately, useless) the application of the Precautionary Principle is, we need look no further than the questions of whether the level of atmospheric carbon dioxide is causing global climate warming, and whether any of the proposed “precautionary” remedies would make things better.

Few seem to have noticed that, while WEEE and RoHS were enacted based on the “Precautionary Principle,” that very principle should have been used to defeat them.

The notion of “threat of harm” from the use of the restricted substances in the targeted applications (i.e., most electrical and electronic equipment) is problematic. Not one case of human health effect due to such use has ever been made public. In the absence of any linkage, or even a plausible mechanism, what meaning can inhere in the phrase “threat of harm”? Is “threat” merely in the eye of the perceiver?

Additionally, there is no basis for exempting the contemplated “precautionary measures” from the same scrutiny as the “current activity.” Simply put, although “Precautionary Principle” formulations don’t explicitly say so, they imply the remedy must not make things worse. But in the absence of proof that the current activity is causing trouble, how could the value of the remedy, be assessed, and by whom?

The prospects for relief from the RoHS directive are bleak. The RoHS Directive is not primarily driven by concern for health and the environment. At the time the EU enacted it, some of the 27 Member States permitted the sale of Pb in gasoline and paint. Any attempt to use science-based reasoning on EU politician/bureaucrats who ignored such reasoning a decade ago would fail. The politician/bureaucrats imposed the RoHS Directive not on manufacturers, distributors or sellers, but on the legislatures of each Member State. It directs each legislature to enact enabling legislation for that state. Thus, even with the EU seemingly on the verge of collapse, virtually all of those legislatures would have to repeal the legislation. With few exceptions, those legislatures are far too busy with far more pressing matters to entertain any appeals for relief.

Even with a global repeal, many component manufacturers, having switched to Pb-free tin as the termination finish, would be reluctant to switch back, asserting they have the whisker problem under control.

If there were to be any hope at all, the CEOs of major electronics equipment manufacturers would have to unite to complain far more vigorously than they have. Their lack of complaint demonstrates clearly to those at the top, as long as all their competitors must also comply, RoHS (with all of its associated headaches for those in the trenches) is “just part of the cost of doing business.”

It may not be clear to all readers why tin is used at all in electronics manufacturing. Surfaces on printed boards and electronic components to be connected by solder must be solderable. Boards and components can be designed and built to have solderable lands without tin. For cost reasons, most components are not. The disappearance of termination finishes other than Pb-free tin is driven not by customers imposing “a single world standard” but by the component manufacturers themselves, who find it too expensive to provide a choice.

Gordon Davy retired in 2007 as an advisory engineer after 34 years at a large defense electronics manufacturer.